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DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80804-Civ-MARRA/JOHNSON CASE NO.: JANE DOE, a/k/a JANE DOE #1, Plaintiff, vs. JEFFREY EPSTEIN, HALEY ROBSON, and SARAH KELLEN, Defendants. NOTICE OF REMOVAL July 18, 2008 STEVEN M. LARIMORF CLERK D.S. DIST. CT. S.O. OF FLA. • MIAMI In accordance wit
lez, Case No. 50 2008 DR 001141 (Palm Beach Co. Family Ct.) (1/31/08). If this turns out to be the case, there is complete diversity, regardless of Robson's citizenship. Although the Eleventh Circuit has recently indicated that a district court may not conduct jurisdictional discovery under such circu
Doe is a citizen of Florida. (Am. Compl. ¶ 1.) 6 Jane Doe may, in fact, be a citizen of Georgia. not Florida, as she pled in her Amended Complaint. See New York Post, Jul. 1, 2008 (reporting that "On his way into court [for his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by D
diction. (b) There is no ossibili that the plaintiff can establish a cause of action against under Florida law. (i) The conspiracy claim against Robson must fail. As a general rule, "[a]n actionable conspiracy [under Florida law] requires an actionable underlying tort or wrong." Wright v. Yurko, 44
Doe is a citizen of Florida. (Am. Compl. ¶ 1.) 6 Jane Doc may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended Complaint. See New York Post, Jul. I, 2008 (reporting that "On his way into court [for his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by D
3031340, 600:00.rt 64064, 10:0100 33133 301316 EFTA00180409 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 4 of 100 Robson, besides having nothing to do with the substantive allegations of the plaintiff's $50,000,000 case, is a community-college student with no assets w
Doe is a citizen of Florida. (Am, Compl. ¶ 1.) 6 'Jane Doe may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended Complaint. See New York Post, Jul. 1, 2008 (reporting that "On his way into court [for his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by D
Entities connected to both Haley Robson and See New York Post

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSON
Alfredo Rodriguez
PERSONJack Goldberger
PERSON
Sarah Kellen
PERSON
Marc Rich
PERSON
New York
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSON
Bill Richardson
PERSON
Michael Douglas
PERSON
George Mitchell
PERSON
Abraham Lincoln
PERSON
Samantha Power
PERSONthe Southern District
LOCATION
Palm Beach County
LOCATION
Anderson
PERSON